Taproot Administrative Services, Inc. v. Commissioner

133 T.C. No. 9

UNITED STATES TAX COURT TAPROOT ADMINISTRATIVE SERVICES, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 15396-07. Filed September 29, 2009. R determined that P is ineligible for S corporation status in 2003 because its shareholder was a Roth individual retirement account (Roth IRA). As a consequence, R determined that P is taxable as a C corporation for 2003. Held: The Roth IRA is not an eligible S corporation shareholder. P is taxable as a C corporation for 2003. Steven R. Mather and Kenneth M. Barish, for petitioner. David W. Sorensen, for…